Case No.:50 2009 CA 040800XXXXMBAG

IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA Case No.:50 2009 CA 040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants, STATEMENT OF UNDISPUTED FACTS Defendant Bradley J. Edwards, Esq., offers the following specific facts as the undisputed material facts in this case. Each of the following facts is numbered separately and individually to facilitate Epstein’s required compliance with Fla. R. Civ. P. 1.510(c) (“The adverse party shall identify . . . any summary judgment evidence on which the adverse party relies.”). All referenced exhibits and attachments have previously been filed with the Court and provided to Epstein. Sexual Abuse of Children By Epstein 1. Defendant Epstein has a nexual preference for young children. Deposition of Jeffrey Epstein, Mar. 17, 2010, at 110 (hereinafter “Epstein Depo.”) (Deposition Attachment #1).! ' When questioned about this subject a ts deposition, Epstein invoked his Fifth Amendment right to remain silent rather than make an incriminating admission. Accordingly, Edwards is entitled to the adverse inference against Epstein that, had Epstein answered, the answer would have been unfavorable to him. “(I]t is well-settled that the Fifth Pimeement, Goes mel ssa adverse inferences against parties to EXHIBIT HOUSE_OVERSIGHT_013319